Free Motion for Extension of Time to File Response/Reply - District Court of Colorado - Colorado

Case 1:04-cv-00023-LTB

Document 71

Filed 04/11/2008

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. 04-cv-00023-LTB-CBS THOMAS MINK, Plaintiff, vs. SUSAN KNOX, a Deputy District Attorney working for the 19th Judicial District Attorney's Office, in her individual capacity Defendant.

PLAINTIFF'S UNOPPOSED MOTION FOR EXTENSION OF TIME
Plaintiff Thomas Mink seeks a one-week extension of time, to and including April 21, 2008, in which to respond to Defendant Knox's Motion to Dismiss. As grounds therefor, Plaintiff states as follows: 1. 14, 2008. 2. Plaintiff's counsel needs additional time in which to prepare the response. In Plaintiff's response to Defendant's Motion to Dismiss is currently due on April

particular, the undersigned is scheduled to take the deposition of a defendant physician in Haralampopoulos v. Kelly, 2006CV12898, Denver Dist. Ct., on April 14. This deposition was scheduled several weeks before Defendant Knox's Motion to Dismiss was filed. 3. Marcy Glenn, who has also entered an appearance for Plaintiff, has been out of

state presenting at a bar association meeting. Likewise, this presentation was scheduled long before the filing of the Motion to Dismiss.

Case 1:04-cv-00023-LTB

Document 71

Filed 04/11/2008

Page 2 of 3

4.

Plaintiff has not previously sought an extension of time as to this particular

matter. Further, the undersigned has conferred with opposing counsel, who does not oppose the extension. WHEREFORE, Plaintiff respectfully requests an extension to and including April 21, 2008 in which to file his opposition to the Motion to Dismiss. Dated April 11, 2008 Respectfully submitted,

s/ A. Bruce Jones A. Bruce Jones Marcy G. Glenn ACLU Cooperating Attorneys HOLLAND & HART LLP 555 Seventeenth Street, Suite 3200 Post Office Box 8749 Denver, CO 80201-8749 Telephone: (303) 295-8000 Facsimile: (303) 295-8261 D.C. Box 06 Mark Silverstein American Civil Liberties Union Foundation of Colorado 400 Corona Street Denver, CO 80218 (303) 777-5482 ATTORNEYS FOR PLAINTIFFS

-2-

Case 1:04-cv-00023-LTB

Document 71

Filed 04/11/2008

Page 3 of 3

CERTIFICATE OF SERVICE
I hereby certify that on 4/11/2008, I have caused to be electronically filed the foregoing with the Clerk of Court using CM/ECF system which will send notification of such filing to the following e-mail addresses: David R. Brougham Hall & Evans, LLC [email protected] William V. Allen Assistant Attorney General [email protected]

Served via U.S. Mail: Thomas Mink 1604 S. Lincoln Street Denver, CO 80201 s/ A. Bruce Jones____________________________
3856907_1.DOC

-3-